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#2264225 - 01/03/22 06:27 PM moved up to intermediate small bank
Anonymous
Unregistered

Happy New Year,

And with that new year, my bank is now an intermediate small bank (FDIC). I know we are now subject to the community development test. But are there any additional CRA responsibilities? Particularly in regards to reporting (either to the FDIC or our board). my understanding is, no, there are no *requirements*. However, our plan is to keep the board updated on community development progress as we go throughout the year. Are we missing anything?

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#2264290 - 01/04/22 10:44 PM Re: moved up to intermediate small bank Anonymous
Norman Paperman Offline
Diamond Poster
Norman Paperman
Joined: Aug 2012
Posts: 1,700
48.934476, -114.343735
No regulatory reporting requirement, but the CD test will require quite a bit of massaging.

Begin getting your loans, services, and investments lined out, qualified, and documented. Use the spreadsheet on the below link to organize your data. I use this and simply hand it over to examiners with supporting documentation for each entry; they are grateful for the organized approach.

Finally, begin pulling performance evaluations for similarly situated banks and see how you stack up. You'll be expected to perform on par with your peers. How do your investments compare to peers? How do your CD loans compare? Count and percentage. We use percentage of assets as an indicator.

https://www.kansascityfed.org/community/cra-onesource/cra-onesource-community-development-resources/
_________________________
Maybe you just wanna fly the plane yourself. Well good luck pressing take off, then auto pilot, then land.


CRCM

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#2264318 - 01/05/22 05:52 PM Re: moved up to intermediate small bank Anonymous
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,084
Connecticut
As an ISB more will be expected of you in several ways.
First, the bank's community development activities will go from no responsibility to a critical responsibility, absolutely essential to passing your next CRA exam, even if it's tomorrow. So you have no time to waste. It's important to collect any CD activities (lending, services, or investments) retroactive to your last CRA exam. Yes, you heard that correctly - retroactive to your last CRA exam - or at least one year. Why, because once you become an ISB you are immediately subject to ISB CRA exam standards. In other words, your CD responsibilities began as you were approaching ISB status. I remember asking a Field Review Supervisor about this and she told me in no uncertain terms that as a bank approaches ISB status it is incumbent to engage in CD activities because the CD test will be administered for the bank's very next CRA exam and there is no leeway for not engagin in sufficient CD activity.

Second, although you are not required to report your CRA activity there will be a higher expectation that you are collecting and monitoring your CRA performance. Heck, if I were a CRA officer at an ISB I would be collecting and monitoring the data whether I was reporting or not because my bank (and I) would be held responsible to perform under CRA. What sane person would subject themselves to that kind of responsibility without collecting and monitoring the data? Of course, if you are a masochist maybe you would enjoy the anxiety of going into a CRA exam blind.
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CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

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